Assessee purchased 48 per cent shares of a company from three entities at a price of Rs. 5 per share. Assessing Officer applying formula contained in rule 11UA, valued the shares at Rs. 45.72 per share and made addition of difference amount to assessee’s income Tribunal deleted the addition on the ground that formula applied by Assessing Officer to arrive value of subject shares was not applicable to assessment year 2014-15.Formula became effective only from 1-4 2018 (AY. 2018 19). Order of Tribunal is affirmed. (AY. 2014-15)
PCIT v. Minda SM Technocast (P.) Ltd. (2023) 295 Taxman 517/ 334 CTR 920 / (2024) 460 ITR 7 (Delhi)(HC)
S. 56 : Income from other sources-Valuation of shares-Book value of assets-.Formula adopted by the Assessing Officer is not applicable to the relevant assessment year-Order of Tribunal deleting the addition is affirmed by the High Court. [S. 56(2)(viib), R.11UA]